The four criteria above were provided by the State Administration of Taxation as supplements to the three requisites for the determination of “actual management structures” specified in the Interpretation of Regulations on the Implementation of the Enterprise Income Tax Law of the People's Republic of China. Chinese-controlled enterprises registered overseas that meet all the four above criteria simultaneously, even though registered overseas, should pay enterprise income taxes as tax resident enterprises of China on their incomes from sources within and outside China, where the actual management structures of such enterprises are determined by Chinese taxation authorities as located within China.
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